In an en banc decision, the U.S. Court of Appeals for the Second Circuit recently addressed the question of whether a New York landlord that does not curtail "tenant-on-tenant" harassment could be subject to a claim for housing discrimination under the Federal Fair Housing Act and the New York State Executive Law pursuant to a "deliberate indifference" theory. Francis v. Kings Park Manor, 992 F.3d 67, 75 (2d Cir. 2021).